When Grand Corps Malade Makes a Voice Sing… Without Permission

The Paris Court of Appeal has handed down a noteworthy ruling on the protection of the human voice as a personal attribute, in a dispute opposing a well-known French music journalist and author to the artist-performer Grand Corps Malade, his production company Anouche Productions, and Universal Music France.

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1. The Facts: When an Interview Turns Into a Sample

In April 2021, Mr. [I], a journalist and author, gave an interview on the webradio Arts-Mada, where he made controversial remarks about the physical appearance of singers, lamenting the disappearance of “handsome performers.”

A few months later, Grand Corps Malade released the song “Des gens beaux” (Beautiful People), conceived as an artistic response to those statements. The track incorporated 33 seconds of Mr. [I]’s actual recorded voice — without his consent — inserted at several points in the song and synchronized in the music video.

Arguing that his voice had been used for commercial purposes without authorization, Mr. [I] sued Anouche Productions and Universal Music France before the Paris Judicial Court, claiming infringement of his right to his voice, as well as of his copyright and related rights.
In May 2023, the lower court dismissed all his claims, holding that the song was protected by artistic freedom. Mr. [I] appealed.

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2. Legal Issues: The Right to One’s Voice vs Freedom of Artistic Expression

Before the Court of Appeal, the debate centered on balancing two equally protected rights:

• the right to one’s voice, as a personal attribute safeguarded by Article 9 of the French Civil Code;
• freedom of expression and artistic creation, invoked by Grand Corps Malade and his producers.

Mr. [I] maintained that his recognizable voice had been exploited for commercial gain, taken out of context, and associated with a controversy long since over.
The respondents contended that the song was an artistic response to a matter of public interest — referencing the #MeToo movement and gender equality — and argued that the voice was not identifiable by the general public.

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3. The Court’s Ruling: An Identifiable Voice Protected by Article 9

The Paris Court of Appeal adopted a firm yet balanced stance:

• It confirmed that a person’s voice is a protected attribute of personality under Article 9 of the Civil Code, and that Mr. [I]’s voice was identifiable, at least by his close circle and by the audience aware of the controversy.
• It held that reproducing the voice was neither necessary nor proportionate to the artistic aim pursued: the song could have criticized the statements without using the actual recording.
• The Court further considered that the issue of “the physical appearance of singers” did not amount to a matter of genuine public interest engaging societal debate.

Accordingly, the unauthorized use of the voice exceeded the limits of freedom of expression and constituted an unlawful infringement of the plaintiff’s right to his voice.

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4. Other Claims: Copyright and Related Rights Rejected

The Court confirmed the dismissal of the copyright claim, ruling that the expression “des gens beaux” (“beautiful people”) was too commonplace to qualify as an original creation.
It also rejected the claim based on related rights, finding that the interview recording did not amount to an artistic performance within the meaning of the Intellectual Property Code.

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5. The Outcome: Damages and Removal Order

The Court of Appeal:

• partly overturned the lower judgment;
• ordered Anouche Productions and Universal Music France to pay €10,000 in moral damages to Mr. [I];
• ordered the removal of his voice from all future exploitations of the phonogram and the video clip, subject to a €500-per-day penalty after a four-month grace period;
• and granted an additional €10,000 under Article 700 of the French Code of Civil Procedure for legal costs.

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This decision reinforces the recognition of the “right to voice” as an extension of the right to image, setting clear limits to artistic freedom when it involves the unauthorized use of a person’s identity attribute.
Grand Corps Malade may sing about beautiful people, but not with someone else’s voice.